Motor vehicle parts classification: EPS-ECU held classifiable under heading 8708 as an integral steering system component.

EPS-ECU and its parts were classified under heading 8708 as motor vehicle parts because the unit had no independent function and operated only as an integral part of the electric power steering system with the torque and speed sensors. The Tribunal treated the goods as specially designed for use in automobiles and found that they were not more specifically covered under headings 8537, 8543 or 9032. Applying the tariff scheme and relevant section notes, it accepted the Department's classification under CTH 8708 94 00 and rejected the competing residual classifications.

---

---

Issues: Whether EPS-ECU and its parts were correctly classifiable under heading 8708 as parts of steering columns and steering boxes, or under headings 8537, 8543 or 9032.

Analysis: The dispute turned on whether EPS-ECU was an electrical machine or apparatus having an independent function, or merely a part of the electric power steering system of an automobile. The Tribunal followed its earlier decision in the same assessee's case and held that EPS-ECU performs no independent function of its own, but works in tandem with the torque sensor and speed sensor as an integral part of the steering system. It was also held that the goods were specially designed for use in automobiles and were not more specifically covered elsewhere in the tariff. Applying the tariff scheme and the relevant section notes, the Tribunal accepted the Department's classification under heading 8708.

Conclusion: EPS-ECU and its parts were held to be classifiable under CTH 8708 94 00 and not under CTH 8537, 8543 or 9032.

Final Conclusion: The impugned orders were affirmed and all the appeals were dismissed.

Ratio Decidendi: A goods classification must follow the tariff entry that specifically describes the article as a part of the relevant motor vehicle system, and a component that has no independent function and is specially designed for automobile use cannot be shifted to a more general residual heading merely because it contains electronic elements.

---